Additional Area Assessment REV 2 Comments_20191004

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
Paul Draovitch
Senior Vice President
Environmental, Health & Safety
Duke Energy
526 South Church Street
Mail Code EC3XP
Charlotte, North Carolina 28202
NORTH CAROLINA
Environmental Quality
October 4, 2019
Subject: Additional Area Assessment Work Plan (REV 2) Comments — Marshall Steam
Station
Dear Mr. Draovitch:
On September 17, 2019, the North Carolina Department of Environmental Quality (DEQ)
Division of Water Resources (Division) received the proposed Additional Area Assessment
Work Plan (REV 2) for the Marshall Steam Station. The initial technical memorandum titled
Marshall Steam Station Additional Area Assessment Work Plan describing groundwater and soil
assessment activities for the Marshall Steam Station additional source areas (e.g., coal pile) was
submitted to the DEQ Mooresville Regional Office (MRO) on November 30, 2018. This plan
was subsequently conditionally approved by the Division's Mooresville Regional Office (MRO)
on December 3, 2018. Duke Energy then submitted the Additional Area Assessment Work Plan
(REV 1) on December 7, 2018 that incorporated those conditions. The purpose of the Additional
Area Assessment Work Plan (REV 2) is to propose one additional bedrock monitoring well for
vertical delineation east of the coal pile as requested by the Division's MRO
The Division has reviewed and hereby approves the proposed assessment activities under the
condition that the results are reported in the upcoming revised Corrective Action Plan (CAP).
If applicable, the results should also be incorporated into the revised geochemical and groundwater
fate and transport models for the site. If the results of the modeling show current or future impacts
to groundwater and/or surface water from this area, then appropriate remedial strategies shall be
proposed in the revised CAP.
North Carolina Department of Environmental Quality I Division of Water Resources
P—E512Q� North Salisbury Street 1 1636 Mail Service Center I Raleigh, North Carolina 27699-1636
ora� 919.707.9000

If you have any questions, please contact Brandy Costner (Mooresville Regional Office) at (704)
235-2185 or Steve Lanter (Central Office) at [phone].
incerely,,
X'\
1
Jim Gregson, Deputy Director
Division of Water Resources
cc: MRO WQROS Regional Office
WQROS Central File Copy